Assessing ICD-10 Readiness and System Testing

Now that your practice has reviewed its budget and determined training needs for the ICD-10 code transition, it is time to assess readiness and the systems that utilize diagnosis codes. There may be areas in the practice outside of claims that regularly use diagnosis codes. It is important to conduct a systems inventory to ensure all hardware and software is evaluated for ICD-10 readiness.

Practice Readiness

It is important to identify all the employees that regularly use diagnosis codes and the resource(s) they use to assign those codes. Here are some questions the practice should ask:
• Who in the practice assigns diagnosis codes and how are they assigned?

• Are they assigned in the EHR system or are code books used?

• Are advanced beneficiary notices (ABNs) issued to patients and how are they produced?

• What resources are used for the precertification and authorization process?

Consider the referral process and what resources are used to complete referrals. Assess the practice for any other internal departments that may utilize diagnosis information. It is important to survey the entire practice and staff as part of your readiness plan and assessment.

If code books are used for all or any of these functions, order them early in 2015. Identify diagnoses most frequently assigned. Once identified in ICD-9, recode them with ICD-10 codes. A frequently used diagnosis codes list can be a very useful tool. Provide time for the office staff to practice assigning ICD-10-CM codes.

Keep in mind that physician billing methods are not changing. Physicians will continue to bill and receive reimbursement based on Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding Systems (HCPCS) codes. The diagnosis codes help to support the procedural codes assigned and complete the full patient story.

Systems Inventory

What systems use diagnosis codes? What software or hardware needs modifications or replacement to accommodate ICD-10 codes? It is important to create a checklist of all the systems utilized in the practice and if diagnosis codes are associated with that system. Assess the entire practice for any system that utilizes coded data and include those systems in the systems inventory.

Vendor Readiness

Conversations with vendors should have already taken place. CMS has a wealth of resources available for physician practices. For a complete list of vendor readiness questions and tools, utilize their "Road to 10" quick references (available here: bit.ly/ICD10-references). The AMA also has resources available for members and nonmembers (bit.ly/AMA-ICD10-references). The American Health Information Management Association (AHIMA) provides many resources for members and nonmembers as well (bit.ly/ahima-ICD10).

Important questions to ask vendors are:

• What system upgrades are needed?

• What is the cost?

• When will the system be ready for testing and implementation?

• What is the availability of customer support?

• Will the system accommodate both ICD-9 and ICD-10 codes?

Systems Testing

Trading partners (your clearinghouse and/or billing system), the practice management system, and the EHR are the major systems that need to be tested. Consider how superbills or encounter forms are generated in your practice (i.e. paper vs. electronic). Check the practice's systems inventory to ensure that all hardware and software that utilize coded data are tested.

If a billing service or clearinghouse is used to submit claims, a discussion surrounding changes the practice may need to make in order to send claims data is needed.

The early identification and resolution of issues discovered during testing will minimize the impact at implementation.

Internal Testing

Talk to your vendor about testing and its availability to assist in the process. Internal testing should already be underway. Test the system's ability to:

• Produce ICD-10 codes;

• Produce an order or requisition with ICD-10 codes;

• Produce a claim;

• Produce an ABN; and

• Generate reports.

External Testing

This should test the ability of the practice to send and receive transactions with ICD-10 codes. Many trading partners have been conducting both internal and external testing in order to be prepared for the ICD-10 implementation. Contact trading partners to determine what testing has taken place, and the results. External testing provides information on the ability to:

• Send test data to an external source;

• Receive coded data from an external source; and

• Identify issues that obstruct the ability to send and/or receive test data.

CMS Acknowledgement Testing

CMS has identified several weeks in 2015 for acknowledgement testing. This testing determines if your claim is successfully transmitted to CMS. This is the first step in the claims submission process. The testing does not test the entire claim process. During the identified weeks, the data is analyzed to provide information on the claims submission process; such as the percentage of claims that were successfully accepted and reasons why claims were rejected. Providers do not need to register for acknowledgment testing. CMS will make the data available once it has been analyzed.      

CMS End-to-End Testing

CMS will be conducting end-to-end testing, which tests the entire claims process from submission to remittance.

Per CMS, the goal of this testing is to demonstrate successful submission of claims with the production of accurate remittance advices.

End-to-end testing, at the time of publication, was scheduled for Jan. 26 through Jan. 30, 2015. Providers participating in this round were selected and notified in October 2014. Fifty registered volunteer providers were selected by each Medicare Administrative Contractor (MAC). There will be two additional testing weeks, in April 2015 and July 2015. To participate in the April testing, registration needed to take place in December of 2014. For information on registering for the July testing, visit the MAC website here: bit.ly/MAC-jurisdictions.

Contingency Planning

As with all new implementations, it is important to have a contingency plan. A practice needs to be prepared for any problem that may arise. A contingency plan will help reduce the impact of any unforeseen event. Examples of items to include in the plan:

• System(s) down time and process;

• Power failure;

• Vendor(s) readiness/lack of readiness;

• Change in vendor(s); and

• Claims denials and/or rejections.

Resources

• CMS acknowledgment testing

• CMS end-to-end testing

• CMS Provider resources

• AHIMA ICD-10-CM/PCS Implementation Toolkit

• AHIMA ICD-10-CM/PCS Transition: Planning and Preparation Checklist

Patty Buttner, RHIA, CDIP, CCS, is a director of Health Information Management Practice Excellence at AHIMA. She can be reached at patricia.buttner@ahima.org.

© 2015 American Health Information Management Association (AHIMA). Reprinted by permission.

This article appeared in the March 2015 issue of Physicians Practice.